Implementing legislation for Integrated Permitting Monika Pribylova 1 October 2013 года Air Quality Governance in the ENPI East Countries

StrategyEnv. permitting lawImplementing legislation In EU, there are countries which have:  no implementing legislation but many more or less compulsory guidelines,  one ordinance or regulation covering all necessary forms and instructions for the implementation,  Several regulations or decrees with individual forms and instructions

Scope of the implementing legislation Application form and instructions how to fill it in Scope of the statement from concerned authorities Permit form Any compulsory methodology – e.g. the content of BAT guidance Instructions on setting up and organizing the BAT support body or system of information exchange on BAT

Application form for integrated permit – content 1/3 A.Data on the company B.Environmental management system C.Data related to the installation and its location D.List of raw materials, secondary raw materials and other substances and energy consumed or produced E.Description of emissions from the installation into all media and establishment of significant consequences of emissions on the environment and human health

Application form for integrated permit – content 2/3 F.Description of the environment at the installation site G.Description of measures and equipment used for control of the installation and emissions H.Detailed analysis of the installation in relation to BAT I.List of measures after shutdown of the installation for avoiding all pollution or human health threats and remediation of the site

Application form for integrated permit – content 3/3 J. Identifying participants in the process if the installation would have transboundary effects K. Statement of the operator with signature L. Abbreviations and symbols M.Annexes N.Proposal of integrated permit conditions

Application form - proposal of permit conditions The content corresponds to the integrated permit content. For existing installation it should among others contain improvement program for compliance with BAT guidance. It represents the wish of the operator how the binding conditions in the permit should look like. This can be accepted by the regulator, or it becomes a base for negotiation.

Integrated permit template is based on the recommendations for the environmental permitting law addresses all of the requirements of the Industrial Emissions Directive 2010/75/EU all environmental media are addressed along with emissions and environmental monitoring contains examples of conditions that could be set for an installation.

Integrated permit template - Integrated permit template - content 1.Description of the installation and connected activities and its location 2.Operating conditions incl. ELVs and other requirements to protect environment, reporting and improvement program 3.Expiring of existing permits 4.Justification 5.Information about appeal

Operating conditions – scope 1/3 1.Emission limits for air and water protection and monitoring

Operating conditions – scope 2/3 2.Emissions to land and related monitoring 3.Site and Roads 4.Prevention of accidents and minimisation of their effects 5.Management (e.g. operational instructions) 6.Incidents and Complaints 7.Efficient use of raw and supplementary materials and water 8.Energy efficiency 9.Waste storage, handling, recovery or disposal

Operating conditions – scope 3/3 10.Noise and Vibration 11.Closure and Decommissioning 12.Reporting on assessment of the compliance with permit conditions 13.On site monitoring 14.Improvement program

Recommendations Firstly set up scope of the permit conditions. Design the application form, which will give you relevant information for making decision about permit conditions. It is useful to test both the application and the permit. Well structured application with relevant information is preconditions for smooth and efficient permitting procedure.

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